Page v Smith [1996] AC 155

House of Lords 

Facts: P was involved in a minor car accident that aggravated his pre-existing but mild myalgic encephalomyelitis (ME), making it chronic and permanent. 

Held: The court ruled in favour of Page, stating that he was a primary victim. Court ruled Claimant was a primary victim, it did not matter that C’s psychiatric injury was not reasonably foreseeable as the risk of C’s physical injury was reasonably foreseeable, even though C did not suffer any physical injury.

• Lord Lloyd : P was a primary victim, directly involved in the accident, and therefore within the range of foreseeable physical injury.